Expert Analysis

Luxembourg’s reform agenda continues at pace in 2025, with targeted measures for start-ups and alternative investment funds

Authors from Khaitan & Co dissect a ‘welcome’ ruling, which found that the mere existence of a tax benefit would not, by itself, warrant a principal purpose test

KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter

Taxpayers may have to refine their approach in staving off tax controversy. A podcast held by ITR in collaboration with CMS explains why audits and tax litigation may never be the same

Join Deloitte and insightsoftware on November 4 for a free ITR webinar exploring how operational transfer pricing transformation can streamline data, improve compliance, and integrate business and financial processes across multinational organisations

How can tax leaders enhance process ownership, manage distributed teams, and balance talent with technology? James Paul of Deloitte UK presents valuable insights from the Tax Transformation Trends 2025 report

David Hamzah Damian of DDTC Consulting examines recent procedural changes in Indonesia’s tax disputes process and the Supreme Court’s stance on tax evidence, highlighting key implications for taxpayers facing audits, objections, and appeals

Eddie Morris, Josep Serrano Torres, and Jen Breeze of Deloitte compare transfer pricing controversies in the pharmaceutical and automotive sectors, highlighting how DEMPE functions, regulation, and intangibles drive both common themes and sector-specific challenges

Shaun Austin and Alexander Duric of Deloitte UK introduce this year’s TP Controversy Guide, offering expert insights into global mutual agreement procedures, litigation trends, and sector-specific transfer pricing issues

Jun Au and Eddie Ahn of DLA Piper Australia analyse the Australian Taxation Office’s framework for applying the third-party debt test and debt deduction creation rules under the country’s new thin capitalisation regime

Fernando Matesanz of Spanish VAT Services explains how EU VAT rules classify digital platforms as deemed suppliers when they act in their own name, outlining the legal, economic, and practical implications

Edouard Authamayou of Deloitte Luxembourg explains an Administrative Tribunal ruling that clarifies the distinction between modification requests and formal tax claims, highlighting procedural requirements for taxpayers submitting claims to the grand duchy’s tax authorities